Subject: File No. S7-06-04
From: Richard Von Luft

March 1, 2004

Helping families achieve financial success means working with their financial portfolios over a long period of time. Rather than charge them fees, which they would not like to pay, using the 12b-1 fees allows me to continue helping them and getting some small compensation.

Is it the position of the SEC to try and put all commission based financial reps out of business? My clients have acheived financial success because I helped encourage and guide them, and sure I made a commission, but do you guys work for free?